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James O’Connell Red Morton Community Park Regional Stormwater Capture Project, Redwood City, CA – Phase 2A 4 June 14, 2021 Our team will prepare an Administrative Draft IS that complies with the requirements of CEQA and supports the City in determining if the proposed project may potentially cause, either individually or cumulatively, a significant effect on the environment. The IS will evaluate, in appropriate factual detail, all aspects of the proposed project using the checklist questions identified in CEQA Guidelines Appendix G. One of the objectives of an IS is to confirm the appropriate level of CEQA documentation for a project. If there is no substantial evidence that the project may cause a significant effect on the environment, either individually or cumulatively, the City may proceed with the preparation of an ND or MND for the proposed project. Although not anticipated, our team will notify the City immediately if evaluations or impact analyses conducted for the IS indicate the proposed project may have a potentially significant impact that could require the preparation of an EIR. The preparation of an EIR will require our team to prepare a separate scope of work for City review. Based on our current understanding of the project, our team anticipates the proposed project will have little or no impact in some of the resource areas analyzed under CEQA because the project area does not include, or the proposed project activities would not have the potential to substantially affect and/or exacerbate, the following resources: Aesthetics/Visual Resources, Agricultural and Forestry Resources, Energy, Geology and Soils, Hazards and Hazardous Materials, Land Use/Planning, Mineral Resources, Population and Housing, Public Services, Utilities and Service Systems, and Wildfire. In addition, the project is anticipated to have a beneficial to hydrology and water quality resources from improved downstream water quality and ground water recharge. The following issues and CEQA-required considerations are expected to be discussed in greatest detail in the Administrative Draft IS: •Air Quality and Greenhouse Gases: The air quality and GHG impacts of the proposed project would be primarily generated during the construction of the project. Our team proposes to prepare a clear and concise air quality/GHG impact assessment that evaluates and quantifies the project’s potential impacts in accordance with the Bay Area Air Quality Management District’s (BAAQMD) CEQA Air Quality Guidelines, the City’s General Plan, and the City’s Climate Action Plan. The analysis will focus on the amount of emissions of criteria air pollutants (e.g., particulate matter, or PM, and oxides of nitrogen, or NOx) and toxic air contaminants (TAC) that would be generated by project construction and operation. Our team will use the California Emissions Estimator Model (CalEEMod) to quantify project emissions and compare project emissions levels against the latest CEQA significance thresholds recommended for use by the BAAQMD. The team anticipates the project would need to incorporate best management practices and/or mitigation measures to reduce project construction emissions, particularly fugitive dust emissions, to less than significant levels. The proposed project is likely to require a large amount of soil excavation and export, on-site heavy duty diesel equipment use, on-site diesel truck idling, and off-site diesel truck trips in close proximity to sensitive residential and other receptors. Our team, therefore, proposes to conduct a construction health risk assessment (HRA) for the project. The team will use the U.S. EPA-approved and BAAQMD- recommended regulatory model (AERMOD) to predict exposure to concentrations of diesel PM, a TAC, at sensitive receptor locations and quantify associated health risks. The constructional HRA will be prepared in accordance with the guidance and recommendations provided by the BAAQMD and the California Office of Environmental Health Hazard Assessment’s (OEHHA) Air Toxics Hot Spots Program Guidance Manual. Our team anticipates the use of late model construction equipment meeting U.S. EPA ATTY/AGR.2021/Amend No. 1/Craftwater Inc (Page 7 of 16)